The purpose of a practice review is to determine whether the practice of a Professional Accountant (SA) and other SAIPA’s designations:
- Has an adequate quality management system in place,
- Complies with the standards set out in the SAIPA Member Handbook,
- Maintains sufficiently high standards regarding generally accepted standards in the profession in rendering services to clients; and
- Adheres to the tax practice standards as approvedrgba(0,0,0,0)#2e336d by SARS and outlined in the Tax Administration Act.
As a self-regulating organization, SAIPA (the “organization”) has a mandate to maintain and improve the knowledge, skill, and proficiency of its members, as well as protect the public. The ways in which SAIPA fulfills this mandate is through quality assurance; which is a programme of inspecting and reviewing members in practice carrying out compilations or reviews of financial statements or bookkeeping, other assurance, or all other service engagements (e.g., tax, business advisory etc.). Practice review provides an educational experience to members, further protecting the public.
- Programme Objective and Scope
- Files Subject to Inspection
- Selection of Offices for Review
- Practice Review Cycle
- Scheduling the Practice Review
- Cancellation of a Scheduled Practice Review
- The Practice Review
- Desk Reviews
- Reportable Deficiencies and Non-Reportable Matters
- PRO Recommendations
- Consistency Review and Committee Review
- Public Practice Committee
- Practice Review Assessors
Programme Objective and Scope
The objective of the practice review programme is the protection of the public by assessing compliance with professional standards of members/firms that perform assurance, compilation and other specified engagements, and by taking appropriate follow-up or remedial action in instances of non-compliance. The public is further protected by practice review in SAIPA providing an educational experience to members/firms engaged in this programme.
The practice review programme is one way to help our members in practice maintain a consistently high standard of quality and service to their clients. Together with high entry standards, training and development requirements, a Code of Ethics and comprehensive professional standards, and legal and regulatory requirements these components are key to upholding the integrity of the Professional Accountant (SA) designation.
Reviews are performed by SAIPA Quality Management in terms of SAIPA’s Quality Assurance and Practice Review Framework that was approved in February 2022. One of the requirements is that SAIPA must, at least on a 3-year risk-adjusted cycle, inspect or review a SAIPA registered practice. However, risk factors are considered, and practice reviews may occur more frequently if considered necessary. By performing these inspections, SAIPA abides by our mission to protect the financial interests of the South African public and investors.
Files Subject to Inspection
All engagements addressed by the standards in International Standards on Quality Management ISQM1 & 2, the ISQM are subject to inspection. Inspection can include, but is not limited to:
- Compilations engagements
- Financial statements or bookkeeping,
- other assurance or all other service engagements (e.g., tax, business advisory etc.)
- Quality management including but not limited to quality management manuals, Continued Professional Development
Practice Review Cycle
Members are selected for assessment at the start of the year. All offices are reviewed on a 3-year risk-adjusted cycle and must be reviewed within 3 years from when their previous practice review was completed. However, risk factors are considered, and practice reviews may occur more frequently if considered necessary. Factors which might indicate a more frequent inspection than every 3 years include:
- A new firm or office
- Firm is newly registered with the Independent Regulatory Board for Auditors (IRBA),
- Significant increase in reporting by clients
- Change in practice profile of the firm, such as taking on new types of engagements
- Merger or a loss of a significant number of partners or a number of new partners
- Discipline decisions
- Failure to meet Continuing Professional Development (“CPD”) requirements
- Weak history of practice review results
- Other information coming to the attention of SAIPA
Selection of Firms for Review
Practice reviews are conducted for each practicing office. Based on an initial self-assessment, being matched with an experienced assessor. As partners within an office conduct their work on firm letterhead and share liability for the work issued by the office, all partners must be accountable for the work completed by their fellow partners. As such, all partners in the office are practice reviewed together.
Furthermore, if other senior individuals within the office have been given the authority to issue or release financial statements or tax returns, they are also required to be licensed and will be included in the scope of the practice review. The cumulative findings for all the files inspected drive the overall practice review result for the office; therefore, the deficiencies of one partner could potentially result in the entire office being found to not comply with professional standards, thereby subjecting the entire firm to a re-inspection.
Once you have been selected for review, we will send you instructions outlining any actions you need to take prior to the review taking place. Completing these actions as requested will help to minimise the time.
When selected you will:
Receive an information pack including a confirmation of details form to enable us to match you with a PRO. Once matched, your PRO will contact you to schedule your face to face or online assessment. They will also schedule an online planning meeting at a convenient time two, weeks prior to your assessment.
You will be asked to complete an online self-assessment and to share documents with us to help us better understand how you operate your business.
After your assessment you will receive an Action Plan including recommendations to support your business.
Based on the results of the practice review, if the office is determined not to be non-compliant with professional standards it will be subject to re-inspection.
The re-inspection will typically focus on those practice areas where the office was not complying with the standards. All partners and partner equivalents of the office are included in the re-inspection. This is irrespective of the fact that only one partner may have had been found to be the non-compliant.
Scheduling the Practice Review
The PRO will also try to gain a better understanding of the practice areas for each of the practitioners to determine the amount of time to set aside for the review. The general rule of thumb is that that PRO will take at least one full day per assurance practitioner as a minimum .
The office will receive a call from a PRO, at least a month in advance of when the PRO would like to schedule the review date, to confirm logistics and request a client list for file selection. The member should have an up-to-date client list available for the reviewer to assist in the file selection. This list should be organized by SAIPA’s practicing Member and indicate the type of engagement.
Files will be selected by the PRO in consultation with the member in charge. The member/practice will be given enough time prior to the visit to ensure that the files are uploaded on SAIPA’s Practice Review Platform for the PRO to access.
Notice of the selected files is based on the completed self-evaluation assessment, which is typically given one month before the scheduled review date. The files provided normally include the current working paper file(s) for the most recent year-end:
- Compiled Financial statements,
- Submitted Tax returns,
- Permanent files
- Engagements and correspondence with clients.
The client list will be requested by the PRO much earlier in the review process. Files will be selected in-house by SAIPA from the client list and the selected files will then be uploaded on the Practice Review platform (CRM) for a review. The Practice Review Coordinator will notify the practice approximately one week prior to the review date as to which files have been selected for review.
The office will receive an email from SAIPA confirming the date set for the practice review. This email will contain a link to a questionnaire (self-evaluation) and Functions-Related Management Questionnaire that must be completed and sent back to SAIPA at least within 7 days after the email was sent. The member will be required to complete a Confidential Client List used for file selection.
The engagement files will then be reviewed to determine that they meet professional standards and the items noted will be discussed with the member in charge of the engagement. The reviewer will provide copies of their notes on the engagement to that member. The member is encouraged to discuss the reviewer’s findings and, where available, provide additional information to the reviewer.
The reviewer will summarize the findings on the engagement files and will determine if additional procedures are required. This summary of findings (Findings Report) as well as the reviewer’s recommendation of ‘Compliance’ or ‘Non-Compliance’ will be discussed with the practitioner in charge of the review (and, at the practitioner’s discretion, with other partners or staff members) at the exit interview. The practice will be asked to sign-off on the Findings Report at that time. The practice will be provided with a copy of the final Findings Report at the end of the practice review for reference and action plan implementation.
The Practice Review
The scope of the practice review primarily covers the assurance and accounting practice of the practice and its system of providing tax services. Other services such as bankruptcy or management advisory services are not directly encompassed by the review, except to the extent that they are associated with professional standards.
Practice reviews are primarily intended to evaluate whether a Practice’s quality management policies and procedures for its accounting, assurance, non-assurance, and tax services are appropriately comprehensive and suitably designed.
The office will need to ensure that all engagement files are available and ready to be pulled if selected for inspection. The Practice Review Officer (“PRO”) will inspect a sample of files and provide a summary of reportable deficiencies and non-reportable matters to the practitioner for discussion.
Practitioners will have an opportunity to address the deficiencies and provide further information or clarification which may result in changes to the deficiencies. Upon completion of the review, the PRO will provide the office with their findings and recommendations in a PRO report.
Throughout the process, practitioners are encouraged to ask questions or discuss issues and practice matters with the PRO.
During an onsite review, the PRO will, among other things:
- Ask to visit the site;
- Request availabilities of the inspectee (for subsequent discussions);
- Explain the process of the inspection and the standards which will be used during the review;
- Obtain the list of clients;
- Obtain the Quality Assurance Manual;
- Inform the inspector that he/she must provide a copy of all selected reports and financial statements.
Cancellation of a Scheduled Practice Review
Practice reviews are scheduled by completion of the Scheduling Questionnaire with a view to making the most efficient use of the Practice Review Officers (“PROs”) time. Once the Scheduling Questionnaire has been returned, it is reviewed to determine the length of the time needed to conduct the review. The Practice Review Coordinator will then contact the firm to schedule the dates(s) for the review.
The current short notice (within 15 working days of the scheduled start date) cancellation fee is R1000. The fee may be waived for extenuating circumstances.
For members in business, public sector and academia, SAIPA conducts a desk review. Instead of a Practice Review Officer visiting a physical site, specific files are uploaded on-to the Practice Review Platform based on the self-evaluation questionnaires completed by the member. Questions arising from the inspection will be addressed via email/phone or during an in-person meeting with the practitioner and the PRO. Once the questions are resolved, the Practice Review Officer’s report is provided either electronically or at the end of the in-person meeting.
Practitioners whose inspections are performed as a desk review are contacted by professional staff at least one month before their scheduled inspection due date to discuss file selection and other logistics.
Reportable Deficiencies and Non-Reportable Matters
Reportable Deficiencies include both material and non-quantifiable matters that do not meet the required standards or regulations or constitute a breach of the SAIPA Code of Professional Conduct. Examples of which would include, a material or non-quantifiable error in financial statements, omission of required disclosures, incomplete or inadequate procedures and documentation, non-compliance with the rules on independence, etc.
Non-reportable Matters include immaterial matters or suggestions for best practice.
Examples would include the use of templates or checklists in file documentation.
The PRO report may also include recommendations to be completed in a specific timeframe such as:
- An action plan in response to the identified reportable deficiencies be drafted and provided to SAIPA within 30 days
- Recommended/required professional development courses
- Approval or loss of pre-approved training privileges, where applicable
- That a re-inspection take place within a year to ensure the firm is complying with professional standards
All reportable deficiencies must be addressed immediately, and recommendations are expected to be acted upon in the time frame specified.
Members can use this link to obtain a template for an action plan.
Practice Review Committee/Consistency Review
Once the practice review has been completed, it will be submitted to SAIPA’s Practice Review Committee. This committee conducts a full review of the inspection file to ensure that they agree with the overall findings and recommendations of the PRO and that the result is consistent with that of inspections with similar findings.
Once agreement has been reached, the files with deficiencies are then assigned to various Committee members, on an anonymous basis, to perform a final independent review of the findings and recommendations. If the Committee member(s) assigned to the review agree with the results, then the review goes to the QAPR Manager for final approval. After the Committee process, offices or members then receive a letter advising on the final results.
Draft Practice Review Report
Practice review of report: Copies of the Draft Practice Review Report will be forwarded to the firm for review from the QAPR Unit of Practice Review in advance for presentation to the Practice Review Committee. Prior to submitting the report to the Committee, the practice must acknowledge the contents by signing the last page of the Draft Practice Review Report and returning it to SAIPA by the specified deadline. The Committee encourages members to submit written comments concerning the content of the Draft Practice Review Report. There may also be times when a response from the practice is required, and this will be noted in the report. The Committee considers both the Draft Practice Review Report and the practice’s comments when forming its assessment of the practice.
Committee Assessment: The report is presented to the Committee in a manner which protects the identity of the practice, its members, and clients. The Committee makes the decision regarding adherence to professional standards. The Committee may reject, modify, or accept the recommendation concerning compliance by the reviewer. The Committee may also request additional information from the practice prior to making its final assessment.
Committee Decision and Recommendations: The practice will be notified of the Committee’s decision and recommendations.
Retained and destroyed files: The Practice Review Report, Decision Letter, Scheduling Questionnaire, and other Questionnaires are retained for a period of four years once a practice has been found to comply and practice review fees are paid. All other working papers, detailed notes, client lists, etc. are destroyed after one year.
Follow-up scheduled (if required): For a Practice receiving a non-comply decision, a follow-up Practice Review will be scheduled within 12 months of the initial practice review visit. This time frame is at the discretion of the Practice Review Committee.
What happens at the end of a review?
The outcome of a review is determined by the reviewer’s findings, which are discussed with the relevant party e.g. practices/member prior to being finalised and submitted to SAIPA.
The action, if any, needing to be taken because of the review is dependent on the issues noted. In rare cases, where no system of quality management is in place and/or serious non-compliance issues are noted, practices/members may be referred to the Quality Review Committee or Investigation Committee/Disciplinary Committee (IC/DC).
Tips for a Successful Practice Review
Practices that are compliant generally:
- Encourage members to attend professional development courses
- Are aware of events within the profession
- Are aware of revisions to the SAIPA Members’ Handbook
- Have adequate working paper file documentation
- Maintain a strong system of quality management
- Prepare for the practice review by maintaining high standards of practice on a continual basis
- Have a cooperative attitude that makes the process more time and cost efficient for both parties
If you have any questions or require further information prior to your practice review, please contact Sechaba Motaung – Professional Accountant (SA), Quality Assurance and Practice Review Manager at firstname.lastname@example.org.